If a foreign corporation that is a per se corporation pays an income tax to the country in which it is organized, then

A - Assuming no subpart F income, there is no foreign tax credit eligibility until a dividend is paid to a US non-corporate shareholder and taxes are withheld

B - Only a U.S. shareholder that is a C corporation which owns at least 10% of the foreign corporation and which receives an actual dividend distribution from the foreign corporation may claim a foreign tax credit for the foreign taxes paid by the foreign corporation when it also takes the 100% dividend received deduction.

C - No foreign tax credit will be allowed to a US shareholders if it is a CFC with some Subpart F income.

D - A less than a 10% shareholder of a CFC will be eligible for a foreign tax on the tax paid for subpart F income that is passed to him when earned by the corporation.